Privacy Policy

1. Who we are and what this policy covers

Luma Kids (“Luma Kids,” “we,” “us,” or “our”) is the operator responsible for the processing described in this policy. This policy applies to the Luma Kids marketing website at lumakids.org, the web app at https://app.lumakids.org/, and Luma Kids mobile applications (together, the “Services”).

This policy does not govern an app store, operating-system provider, external website, or other third-party service that has its own privacy practices. When a third party processes information for Luma Kids, the relevant processing is described below.

2. Information we do not ask children to provide

Luma Kids does not require an account. The Services do not ask a child to submit a name, email address, telephone number, home address, date of birth, school, diagnosis, photo, voice recording, drawing, or other free-form communication. The Services do not provide public profiles, public rooms, chat, or direct messaging.

We do not knowingly collect health or diagnostic information. Visiting a page about ADHD-friendly games does not tell us that a visitor or child has ADHD, and we do not infer a diagnosis from that visit.

3. The marketing website

The marketing website has no account, contact form, analytics service, advertising pixel, fingerprinting, session replay, or marketing cookie. It does not use a visitor's activity for advertising or cross-site tracking.

When the website is requested, hosting and content-delivery systems may process standard request information such as an IP address, browser and device type, requested URL, date and time, referring page, and security events. This is necessary to deliver the website, maintain reliability, prevent abuse, and diagnose faults.

The marketing website retrieves font files through Google Fonts. As a result, Google may receive standard request information, including an IP address and browser details, when the font is requested. Luma Kids does not use Google Fonts to track visitors or receive visitor-level reports.

The “Share to mobile” and “Copy link” controls use the browser's share sheet or clipboard. Luma Kids does not receive the contents of the share or clipboard operation.

4. Information stored only on the device

Solo gameplay information is stored locally on the device. It may include:

• language and difficulty settings;
• adaptive game progress;
• daily activity and game rotation;
• Sun Points;
• owned and placed garden plants and garden-care dates; and
• the selected colouring mode.

This information is not synchronized to an account or uploaded as gameplay progress. Luma Kids cannot access, recover, correct, or remotely delete it. A parent or guardian can remove it by clearing the app's storage, clearing the browser's site data, or uninstalling the app. Doing so may permanently reset progress.

Colouring strokes and completed pictures are not stored by Luma Kids.

5. Limited usage measurement

The app sends limited events to help us confirm that the games work and understand aggregate game use. An event may indicate:

• the first use of an app installation;
• one active-use count for a local calendar day;
• that a named game was started or completed; or
• that a Petal Pairs multiplayer game was started or completed, including connection type and player role.

These events do not include a name, account, advertising identifier, precise location, age, score, gameplay progress, garden information, drawing, completed picture, or stable child profile. Network systems may still process an IP address and standard request information while transmitting an event. One-time event hashes are used to prevent duplicate counting and are deleted after approximately 45 days.

Events are converted into daily aggregate totals. We do not maintain a child- or device-level usage history from these events. Aggregate totals that no longer relate to an identifiable or reasonably identifiable person may be retained for operational and statistical purposes. We use the term “anonymous” only when information has actually been rendered non-identifiable; pseudonymous information remains protected as personal information where applicable law says it does.

6. Optional multiplayer and camera access

Petal Pairs offers optional two-player multiplayer. Online multiplayer processes a temporary four-digit room code, temporary host and guest credentials, limited messages needed to synchronize the match, and network information such as IP addresses needed to route, secure, and rate-limit the connection.

Unused room codes expire after approximately five minutes. Active multiplayer rooms expire after approximately 45 minutes. There is no multiplayer chat or permanent match history. Solo progress, Sun Points, garden information, colouring data, and unrelated device information are not included in multiplayer messages. Online multiplayer uses encrypted HTTPS and WebSocket connections.

Local multiplayer can connect two devices over a local network using encrypted WebRTC and QR codes. WebRTC may expose network addresses to the connected peer and network infrastructure as needed to establish the connection. Camera permission is requested only after the QR-code scanner is opened. Camera images are processed on the device for QR recognition and are not uploaded or stored by Luma Kids. The user may decline camera access and use another available connection method where supported.

7. Messages sent to us

If a parent, guardian, or other adult emails us, we receive the sender's email address, message, and any information they choose to include. We use it to answer the request, protect the Services, keep necessary business records, and meet legal obligations.

Please do not email a child's name, diagnosis, drawing, photo, or other unnecessary personal information. If we learn that a child sent personal information unexpectedly, we will investigate and delete it where legally required and technically possible.

8. Why we process information and our legal bases

We process the limited information described above to:

• deliver the website, games, and multiplayer features a user requests;
• maintain network communications and app functionality;
• secure the Services, rate-limit requests, and prevent fraud or abuse;
• debug faults, maintain reliability, and prevent duplicate events;
• understand aggregate game use and improve the Services;
• respond to adult support and privacy requests; and
• comply with law and establish, exercise, or defend legal claims.

Where the GDPR, UK GDPR, or a similar law applies, the legal basis depends on the purpose. Requested functionality may be necessary to perform an agreement with an adult or take steps at the adult's request. Security, limited operational measurement, service improvement, and support are based on our legitimate interests in operating a safe, reliable, and privacy-preserving service, balanced against the rights and best interests of children. We process information where necessary to comply with legal obligations. If consent is legally required for a particular activity, we will request valid consent before that activity begins, and it may be withdrawn as required by law.

9. Children and parental choices

Luma Kids is designed for children and applies privacy-protective defaults. We minimize collection, avoid advertising and profiling, keep solo progress on the device, and make multiplayer temporary and optional.

Where the U.S. Children's Online Privacy Protection Act (COPPA) applies, persistent identifiers and network information are used only as permitted to support internal operations, such as providing network communications, maintaining functionality, protecting security and integrity, debugging, and aggregate statistical reporting. We do not use them to contact a child, build a behavioural profile, or serve behavioural advertising. If we introduce processing that requires verifiable parental consent, we will provide direct notice and obtain that consent before collecting the information.

Parents may disable optional multiplayer by not opening or joining a room, decline camera permission, clear local progress, or contact us with a privacy request. Core solo play is not conditioned on agreeing to advertising or unrelated data collection.

10. When information is disclosed

We disclose limited information only in these circumstances:

• Service providers. Cloudflare supports multiplayer delivery, security, rate limiting, and aggregate usage counting. Hosting and content-delivery providers deliver the Services. Google provides website fonts and hosts our contact mailbox. We use these providers only for the functions described here. Their processing is also subject to applicable agreements, law, and their own legal obligations.
• Legal and safety reasons. We may preserve or disclose information if reasonably necessary to comply with law, legal process, or a valid government request; protect rights, safety, and security; investigate abuse; or establish, exercise, or defend legal claims.
• Business changes. If Luma Kids is involved in a merger, acquisition, financing, reorganization, bankruptcy, or transfer of assets, limited information may be reviewed or transferred subject to appropriate confidentiality and applicable law. We will provide notice before personal information becomes subject to a materially different privacy policy where required.

We do not sell personal information, share it for cross-context behavioural advertising, display third-party advertising, or permit cross-service tracking. During the preceding 12 months, we have not knowingly sold or shared the personal information of anyone under 16 for these purposes.

11. Retention

• Local progress: remains on the device until the user clears site or app storage or uninstalls the app.
• Unused multiplayer rooms: approximately five minutes.
• Active multiplayer rooms: approximately 45 minutes.
• Duplicate-prevention hashes: approximately 45 days.
• Aggregate totals: may be retained for operational and statistical purposes once they no longer relate to an identifiable or reasonably identifiable person.
• Technical logs and adult correspondence: retained only as long as reasonably necessary for delivery, security, support, recordkeeping, legal compliance, and legal claims. Retention may also depend on provider settings and legal obligations.

We delete or de-identify personal information when it is no longer reasonably necessary for the purpose for which it was processed, unless a longer period is required by law or reasonably necessary for security, dispute resolution, or legal claims.

12. International processing

Luma Kids and its providers may process information in countries other than the user's country. Those countries may have different privacy laws. Where applicable law requires a transfer mechanism, we use an available lawful mechanism and appropriate safeguards, such as adequacy decisions or contractual protections. Parents may contact us for more information about safeguards relevant to their request.

13. Privacy rights

Depending on location and subject to legal conditions and exceptions, a parent, guardian, or other data subject may have the right to:

• know whether and how personal information is processed;
• request access to or a copy of personal information;
• request correction or deletion;
• request restriction or object to certain processing;
• withdraw consent where processing is based on consent;
• receive certain information in a portable format; and
• complain to the competent privacy or data-protection authority.

Residents of California and other U.S. states may also have rights to know, correct, delete, obtain a portable copy, and opt out of sale, sharing, or targeted advertising, as applicable. Luma Kids does not sell personal information or share it for cross-context behavioural advertising, so there is no such activity to opt out of. We do not discriminate for exercising a privacy right.

Most gameplay information is stored only on the device and is not available to us. Aggregate information cannot be retrieved by a child's name. We may ask for only the information reasonably necessary to verify authority and process a request, and an authorized agent may submit a request where law permits.

14. Automated decisions, tracking signals, and advertising

Adaptive game behaviour is calculated locally to adjust play and does not make legal or similarly significant decisions about a child. We do not use personal information for automated eligibility decisions, advertising profiles, or medical conclusions.

Browsers may offer “Do Not Track” or Global Privacy Control signals. Because the Services do not sell personal information, share it for cross-context behavioural advertising, or conduct cross-site behavioural tracking, there is no sale, sharing, or targeted-advertising activity for those signals to opt out of.

15. Security and incidents

We use technical and organizational safeguards appropriate to the limited information we process. Measures include encrypted network connections, temporary multiplayer credentials, short room lifetimes, request validation, rate limiting, data minimization, and restricted access. Service providers are selected and used for defined operational purposes.

No system is completely secure. If we identify a security incident, we will investigate, contain, and remediate it and notify affected people or authorities when applicable law requires notice.

16. Changes to this policy

We may update this policy when the Services, providers, or legal requirements change. The current version will be published on this page, and we will update the date above. If a change materially affects how we handle children's personal information, we will provide additional notice and obtain consent where required before applying the new practice.

17. Contact

For privacy questions, parental requests, or concerns, contact Luma Kids at lumakidsapp@gmail.com.

To protect children, please describe the request without including a child's name, diagnosis, drawing, photo, or other unnecessary personal information.